On November 26, 2018, the US Internal Revenue Service released an advance version of Revenue Procedure 2018-59 (the “revenue procedure”), which would allow taxpayers providing certain infrastructure-related services in public-private partnerships to avoid the application of the Section 163(j) business interest limitations.

On December 13, 2018, the US Internal Revenue Service released an initial set of proposed regulations addressing a number of open issues under the Base Erosion Anti-Abuse Tax (BEAT) rules. The proposed regulations are scheduled to apply to 2018 tax years. The proposed regulations provide favorable guidance on payments to US branches and the application of the BEAT to services eligible for the service cost method, but transfer-priced at a markup. The proposed regulations also contain a number of rules likely to be challenging to taxpayers, including tracing excess interest to worldwide liabilities, flooring taxable income at zero when a taxpayer has a net operating loss carryover and excluding qualified derivative payments from the denominator of the base erosion percentage. Mark Leeds of the New York office of Mayer Brown explores the proposed regulations under the BEAT rules in this Legal Update, which published in the January 7, 2019 issue of Tax Notes magazine.

Richard looks at some legal developments and deadlines in the pensions industry that will occur, or are expected to occur, during the course of 2019.

For more than a century, a creditor holding English law governed debt relied on the principle (known as the “rule in Gibbs”) that a debt governed by English law cannot be discharged by a foreign insolvency proceeding, provided that the creditor does not submit to that proceeding.

With rapid economic development and rising income, there has been an increase in demand for high-quality education (in particular, private education) in various countries in Southeast Asia. As a result, there has been growing interest from private equity sponsors and institutional investors in the education sector in Southeast Asia.

REVERSEinquiries is Mayer Brown’s structured and market-linked products-focused newsletter.

On January 7, 2019, the US self-regulatory organization the National Futures Association (“NFA”) announced that it had adopted amendments, which become effective April 1, 2019, to its information security requirements that include a cybersecurity incident notification obligation.

The partial federal government shutdown has halted a range of government operations.

This Legal Update discusses a recent court decision that invoked a US bankruptcy court’s authority to act as gatekeeper for involuntary petitions that threaten to undermine bargained-for liquidation procedures.

Nick reviews the 10 key cases for employers in 2018, and what these mean for employers in 2019.

The winter months have seen a range of significant measures in tax legislation, from tax incentives for foreign investment and various measures to promote the technology sector to building on earlier measures to increase tax collections. China reformed its individual income tax law and has extended, with adjustments, its policy on retail imports through e-commerce.

Since the Asian financial crisis of the late 1990s, the region’s high-yield debt capital markets have expanded dramatically. And during the past several years, amid an expanding global economy, issuance volumes have hit record levels, with exciting changes in deal structures and covenant packages.

This four-part multimedia series offers practical insights on high-yield debt for Asia-based issuers seeking to understand important covenants and trends.

On December 27, 2018, an Agreement on Technical Cooperation and Mutual Assistance ("Technical Cooperation Agreement") entered into force between the Brazilian Federal Court of Auditors ("TCU") and the Administrative Council for Economic Defense ("CADE").